Privacy Policy

Last Updated: 02/01/2023
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Pivoting Owl Inc. (“Thena”) provides a solution for businesses to effortlessly track and manage their customers directly in Slack.

This Privacy Policy describes how Thena collects, uses, discloses and otherwise processes personal information in connection with our website and any other sites or services that link to this Privacy Policy (collectively, the “Services”), and explains the rights and choices available to individuals with respect to their information.

This Privacy Policy does not apply to personal information (including name, business email address, link to Slack profile picture, and Slack user metadata) that we process on behalf of our customers. We process this information as instructed by our customers, in our capacity as a service provider/data processor, in accordance with the terms of our Data Processing Addendum.

We use personal information for the following purposes or as otherwise described at the time of collection:

Providing and supporting our Services. We use personal information to operate, maintain, and provide you with our Services. In particular, we will use personal information to perform our contractual obligation under our terms of service, such as to allow you to use the Services.

Communicating with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts and support and administrative messages.

Improving, monitoring, personalizing, and protecting our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:
troubleshooting, testing and research and to keep the Services secure; and

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business. For example, we use anonymized traffic statistics from Google Analytics to recognize and count the number of visitors to the website and to see how visitors move around the website when they are using it to enable us to improve the way the website works.

Direct marketing. We may send you Thena-related direct marketing communications as permitted by law, including by email. Except where consent is required, we undertake such marketing on the basis of our legitimate business interest. You may opt-out of our marketing communications as described in the Opt out of marketing communications section below. Where we seek your consent, you may withdraw your consent at any time by contacting us using the details in the How to Contact Us section below.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to understanding your needs and interests, and personalize your experience with the Services and our communications; troubleshooting, testing and research and to keep the Services secure; and investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

We may share personal information with:
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Service providers. We may share personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, fraud detection, payment processing, and database management).

Professional advisors. We may disclose personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. We may share personal information with law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Opt out of marketing communications. Marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us at legal@thena.ai. You may continue to receive service-related and non-marketing emails.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our services, you may request the following in relation to personal information:

To make a request, please email us or write to us as provided in the How to Contact Us section below.We may ask for specific information from you to help us confirm your identity.

Right to complain. Depending on your location, you may have the right to lodge a complaint with yourlocal supervisory authority for data protection. Click here to find your local supervisory authority.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the How to Contact Us section below.

Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:

Note that because these opt-out mechanisms are specific to the device or browser on which they areexercised, you will need to opt out on every browser and device that you use.
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Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the onlineservices that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out moreabout “Do Not Track,” please visit http://www.allaboutdnt.com.

Our Services may contain links to other websites and other online services operated by third parties.These links and integrations are not an endorsement of, or representation that we are affiliated with, anythird party. In addition, our content may be included on web pages or other online services that are notassociated with us. We do not control websites or online services operated by third parties, and we arenot responsible for their actions. We encourage you to read the privacy policies of the other websites andonline services you use.

Security Practices
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We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure.Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Children
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Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Job Applicants

When you visit the Careers portion of the website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of the services, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our terms of service.

International Data Transfers

You will provide personal information directly to our website in the United States. We may also transfer personal information to our affiliates and service providers in the United States and other jurisdictions.Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the How to Contact Us section below.

We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Services.

How to Contact Us

Pivoting Owl Inc. is the entity responsible for the processing of our business contacts’ personal information (as a controller, where provided under applicable law).

Please direct any questions or comments about this Policy or privacy practices to legal@thena.ai. You may also write to us via postal mail at:

548 Market St
San Francisco, CA 94104